Jim Grassiano – Alabama Department of Environmental Management
Mary Alice Corcoran – Alabama Department of Environmental Management
ADEM Operator Certification
Preliminary Draft Regulation & OC
Program Updates
2020 Alabama Rural Water Association Annual Webinar Series
April-June 2020
Revised Operator
Certification Regulation
We’ve spent a lot of time in the last 18
months talking about the need for a
change to our Division 10 Regulation
We’ve highlighted our intentions about
the OC regulation at various meetings
and conferences
The time has come to move this along and
implement the regulation
Revised Operator
Certification Regulation
Today we’re going to mainly discuss
the details included in the proposed
new regulation
We’re NOT going to spend much time on
WHY we are adopting a new regulation
The Need for A Change
• Implement psychometric exams
• Maintain reciprocity with other states
• Align NTK Criteria with ABC exams
• Update the regulation to reflect broad
operational oversight changes that are
warranted 30+ years after the initial Div
10 regulation came into existence
• Maintain EPA delegated authority
To briefly overview, we must:
“Preliminary Draft”
• Released for general distribution in
early January
• Goal is to get stakeholder feedback
• We will develop a revised Draft that
will go to formal Public Notice in the
months ahead. We WERE Targeting
June 1, 2020. Now TBD.
“Preliminary Draft”
• We have already made several changes in
response to comments…and we do
expect to make more changes
• Many regulation details are open for
discussion
• Some things are negotiable
• Some are not…
“Preliminary Draft”
Once again, we have made significant
changes to the Preliminary Draft that was
distributed in early January:
• Based on Utility/Operator Feedback
• Based on internal ADEM advisement or
Water Division input
“Preliminary Draft”
As well, we have made significant changes to
the Preliminary Draft ranking protocol that
was distributed in early January, also:
• Based on Utility/Operator Feedback
• Based on internal ADEM advisement or
Water Division input
“Revised Preliminary
Draft”
Is now located on ADEM’s Operator
Certification Web Page
The web location is here:
http://www.adem.state.al.us/programs/water/
opcertification.cnt
• The revised regulation and Plant
Ranking Protocols are both on the web
page
http://www.adem.state.al.us/programs/water/opcertification.cnt
Operator Inventory
(as of Feb 2020)
• Total Certified Water
Operators: 2553
– This total number consists of
• 783 Grade IV Water Operators
• 207 Grade III Water Operators
• 838 Grade II Water Operators
• 725 Grade I Water Operators
Est. No. of
Systems
(579 Total
Systems)
• 79
• 26
• 282
• 192
Operator Inventory
(as of Feb 2020)
• Total Certified Wastewater
Operators: 1622
– This total number consists of
• 605 Grade IV Wastewater Operators
• 166 Grade III Wastewater Operators
• 287 Grade II Wastewater Operators
• 122 Grade I Wastewater Operators
• 442 Grade IC Wastewater Operators
No. of
Systems
(482 Plants)
• ≈ 37 (IV)
• ≈ 77 (III)
• ≈ 208 (II)
• ≈ 160 (I)
• ≈ 510 (IC)
Operator Inventory
(as of 1/25/20)
• We have 4175 Certifications issued
• There are 675 people dual certified
• Overall, we have 3500 people certified in
Water and Wastewater programs
Operator Inventory
(as of 1/25/20)
• Main issues to note:
– We have about 50 more WW operators than
last year
– We have about 17 more Water operators than
last year
• We’re heading in the right direction
Operator Inventory
Survey
• On 3/10/20, ADEM sent out a Survey
regarding present and future (5-year
outlook) needs for Water and Wastewater
Operators
• Went to every Water and WW Utility in the
State
• Requested by ADEM’s Director, so the
whole issue of operator needs is getting
good attention
Future Regulation Change
• This will be the most significant change
in ADEM’s OC history since the
inception of the original ADEM rule in
1986
• There are many changes in store
• The preliminary draft phase is an
important time to get your feedback
It’s obvious. Operation is
becoming more challenging…
An Operator must:
Know more…
Do more…
Be responsible for more…
Learn more…
Mentor more…
Sample more…
Than ever before…!!
Protect more…
Lots of things have changed in
30+ (actually 45+) years
CWA – 1972
SDWA – 1974 (see below)
National Primary DW Standards 1985
Surface Water Treatment Rule 1989
Total Coliform Rule 1989
SDWA Amendments of 1986
DBP Regulation 1998
It just keeps going…!!
SDWA – initially Treatment Techniques and 23 MCLs
SDWA Amendments of 1996
Lead and Copper Regulations 1990UCMR 1999
Lead and Copper Rule Action Levels 2000
Filter Backwash Recycl Rule 2001
LT1 Enhanced SWTR 2002
LT2 Enhanced SWTR 2006Stage 2 DBP Rule 2006
Groundwater Rule 2006 UCMR 4 2016-2020UCMR 5 - TBD
Lots of things have changed in
30+ (actually 45+) yearsOf course there is more…much more...
CCRs, Financial Issues,
Enforcement, Industrial
Development, etc, etc.
Feedback Period
• You can email, call us, provide written
review comments, or request a meeting
with us
• We are setting up a series of
workshops…
Planned Workshops to
Discuss the Regulation
• We will have a number of public forums to
discuss the Preliminary Draft regulation:
• [All of the dates will be re-scheduled!]
– March 30: Huntsville
– April 1: Dothan
– April 2: Muscle Shoals
– April 10: Prattville
– April 13: Tuscaloosa
We’re going to focus on
the changes now…
• What is going to be different…?
• How will operators be personally affected
• What about the effect on Utilities?
Plant Ranking
• New numerical ranking system for Water
Plants and Wastewater Plants, based on
treatment complexity, design flow,
population served, and operator
responsibility (e.g., lab work)…among
other things
Plant Ranking
• Yes, your plant classification may change
• However, most plants will not go up in
grade and for those that do, few will
require additional operator staffing
requirements
Wastewater Plant Ranking
• Grade I through IV Treatment
• Grade I WW Treatment plant is no longer
a “lagoon”
Water Plant Ranking
• Also Grade I through IV Water Treatment
• Grade I is no longer a distribution system
• Grade I is now a Grade I Water Treatment
designation
Distribution and Collection
• Distribution and Collection systems will
also undergo a classification process,
based solely on population
Grade ID
Grade IID
Grade IC
Grade IIC
Grade IC and ID = 15,000 or less
Grade IIC and IID = 15,001 and greater
Separating Out Treatment
and Distribution/Collection
• Utilities will need to have a designated
operator(s) for their treatment plant and a
designated operator(s) for their collection
and distribution system
• For small and mid-sized utilities, this can
be the same person(s)
Separating Out Treatment
and Distribution/Collection
• If you are a utility that has not truly had a
dedicated distribution or collection system
operator (i.e., if you have used the current
regulatory ‘loophole’ to avoid this
responsibility), then you need to prepare
for this change
Future Certification Exams
• All exams will be standardized exams
• These exams will be Association of
Boards of Certification (ABC) exams
• All exams are 3-hour exams, except
Grade IV Treatment exams (4-hours)
Future Certification Exams
• Grade IC/D Exams = ABC Grade IC/D
• Grade IIC/D Exams = ABC Grade IIIC/D
- About 161 Cities fall into the IC/D range
- 39 municipalities fall into the Grade IIC/D realm
Alabama -- ABC C&D
Classifications
• Do not completely align
Comparison of Alabama to
ABC C & D Classification
• Grade IC/D = 1,500 or less
• Grade IIC/D = 1,501 to 15,000
• Grade IIIC/D = 15,001 to 50,000
• Grade IV C/D= >50,001
• Grade IC/D = 15,001
Alabama ClassificationABC Classification
Why Different…?
• We didn’t see the need to have
complete alignment
• Making the change to adopt TWO
classifications is believed to be a
notable improvement for Alabama’s
certification program at this time
Interim-Step Exam for
Grade III or IV Treatment
• An operator candidate will have to pass
a Grade II exam prior to taking a Grade
III or IV exam
– Exception for someone holding a 4-year
college degree in engineering or
biological/chemical sciences
EPA Oversight
• EPA is aware of what ADEM is doing to
revise our Division 10 (Op Cert)
regulation
– They are very supportive of the proposed
changes
Staffing Requirements
Red text = notable changes
Keep in mind that: 1. most small WWTPs (e.g., schools, small lagoons)
will be a Grade I WWTP; 2. most Water basic GW systems will be a
Grade I WTP
Grade II Mechanical
WWTPs
• A key issue here is that we anticipate that
many small mechanical plants and ALL
small package plants < 15,000 gpd will be
a Grade I WWTP
Grade II Mechanical
WWTPs
• We have to consider the appropriateness
of what we are trying to achieve:
• Is visiting say a 100,000 gpd mechanical
WWTP only once/week or even three
times/week (as now proposed)
appropriate? Likely not, if the plant is to
be appropriately operated..!!
Please Review Your
Classification
• We did not have the luxury of classifying
ALL of our existing plants
• Please go through the Draft Ranking of
your plant to determine your future
classification and assess any concerns or
implications
• Let us know your concerns
** Make sure you have the latest version of
the Ranking Protocol
Please Review Your
Classification
• The new ranking protocol is an excel file
instead of a writeable pdf
• This allows the person completing the
form to write notes along the way
• Much more user friendly
• The improved ranking process is easier to
follow
• The point brackets for each grade have
changed, however
A Note about the Revised Point
Brackets (e.g., cutoff between
grade of plant)
• Don’t just assume the new staffing
requirements will affect your plant, as the
grade of your plant may go up or down
• But, also note that we do anticipate that
many (perhaps most) existing Grade II
plants will be downgraded to a Grade I
plant…on both the Water and Wastewater
side
Please Review Your
Classification
• The ranking protocol is very simple and only
takes
Collection & Distribution
Staffing Requirements
• For both IC/D and IIC/D systems, the
minimum requirement for an Operator
“Visit” is once every 7 days
• Also “at all times necessary to ensure
safe, efficient, and proper operation”
Collection & Distribution
Staffing Requirements
• Small water distribution and wastewater
collection systems with < 1,000 ft of
water/sewer main will NOT be required to
have a separate Collection and
Distribution operator
• The treatment plant operator will be
responsible for these very small C & D
systems
Tell Us Where you Work
• Every operator will be required** to
submit an operator employment form:
– Standard Operator Employment
– Operator of Multiple Systems
• You will NOT be an operator of record
until you submit this form
• If you change jobs, you must tell ADEM** We will still allow a utility to notify us, when it is most reasonable
to do so (e.g., retirement)
Multiple Systems
• Multiple Systems operators will be
subject to ADEM review:
– Not something we plan to use often, but
we will be auditing unusual situations
– If an operator is found to NOT be meeting
the minimum operator responsibilities at
one of his or her systems, that operator
may be subject to enforcement
Operator Logs
• Required at every treatment plant,
collection, and distribution system
• This is to show the operator of record at
any given time
– Plant operator log kept at the treatment plant
– C &D operator log kept at an approved specified location
Facility Operations
Logbook
• This is the record of all process control
decisions and daily operational
oversight actions made by certified
operators
• This is a “new” operator requirement
– Also kept at the treatment plant
– C &D operations log kept at an approved specified location
– This logbook can be kept “electronically” for a facility (e.g.,
SCADA file or proprietary operations software file)
Facility Operations
Logbook – Operator Intern
• Every operator intern should have his
or her logbook to document the
experience you are attaining
Unpermitted Collection
Systems
• We are unsure how many of these
(sometimes called ‘Satellite Collection
Systems’) are out there. Perhaps 50 or
so…but possibly more.
• They are now required to have a
certified operator
Work Shift Limitation
• 16-hours per day max
• A utility can forego written approval of a
exceptions during weather
emergencies, plant upsets, or staff
illness
• The objective is to restrict ridiculous
typical day-to-day work shifts
Contract Operation
• Utilities are required to ensure that
contracts meet all Division 10 operator
responsibilities
Direct Responsible Charge
• Newly adopted term
• Utilities are to designate who is in DRC
of a Grade III and IV Treatment Plant
and a IIC/IID Collection/Distribution
System and/or to designate who is in
DRC of various major plant/system
functions & responsibilities
Direct Responsible Charge
• We will have more guidance on this
issue forthcoming
• It will NOT be an administrative burden
• In some cases, a Utility may choose to
submit a DRC Plan to ADEM that
outlines intern training roles
Intern in DRC
• This is an important new requirement to
ensure the operator candidate obtains
meaningful on-site operator experience
prior to certification
• This is a distinguishing requirement to
attain Grade III and Grade IV
Treatment…and Grade IIC and IID
certification
Revocation Clause
• For falsifying for any work experience,
including work in DRC and as an intern
in DRC
• Applies to anyone vouching for
experience claimed by an operator
intern
Revocation Clause
Extending Lapse Period
or Sunset Clause
• An operator will have up to 365 days to
recover or retain their certification
• Two incremental late fees:
–
Continuing Education
Requirements
• The term “Dual Certified” will change, as
certification will be required for Treatment
AND Collection/Distribution
• Thus, someone may hold up to 4
certifications
• A future consideration: Does every person
really NEED to have T&C or T&D
certification? Sometimes yes, but maybe not
Continuing Education
Requirements
Example of prospective carryover hours and CEHs
needed to be attained in a 3-year renewal period
This is why there is now a maximum of 5
carryover hours per certification
CEHs for “Equivalent
Working Experience”
• Limited to only 8-hours for exam prep
training classes and only for an
operator candidate pursuing a higher
level of certification
Acceptable CEHs
• Other clarifying changes were made to
limit several other categories of
training:
– 4 hrs for homeland security/anti-terrorism
training as applies to W & WW plants
– No longer accepting CEHs for defensive
driving
– No longer universally accepting CEHs for
temporary traffic control training. Now
only for C & D Operators
Acceptable CEHs
(cont’d)
– 8 hours of Trenching and shoring training
also limited to only collection and
distribution operators
– Formally adding the acceptance of plant
awards inspections
Acceptable CEHs
(cont’d)
Correspondence, in-house, video, and on-
Line training classes:
– Should be pre-approved by ADEM
Unacceptable CEHs
(cont’d)
– Homeland Security/EMA Certification
Classes
– OSHA Certification Classes
– Construction Stormwater [“Credentialed
Inspector Training”]
Certification Renewals
– MUST be submitted online
– No longer accepting hard copy
applications for renewal
Certification Renewals
Our Goal is to EVENTUALLY get to
“Automated Renewals”**
– Operators will print out their own renewal
cards
– Operators will be subject to audits of CEHs
attained
**Automated renewal will NOT be ready by the time
the new regulation is implemented
“Grandfathering”
• All present TREATMENT certifications
will be grandfathered-in to also have an
unrestricted Grade IIC or IID
certification, respectively
• For any treatment plant that increases
in grade: Operators will be issued a
restricted higher grade certification, in
addition to their present certification
Grandfathering Decisions…
…No Comment
“Grandfathering”
• For all existing Grade I Water
Operators:
– You will be issued a Grade ID certification
“Grandfathering”
• For all existing Grade I Water and
Grade IC Wastewater Operators:
– You will be issued a restricted Grade IIC or
Grade IID certification, if your system
classification increases
– Otherwise, you will retain your equivalent
IC or ID certification
Reciprocity
• Reciprocity with Alabama will only be
granted to operators who pass a
comparable written exam in a reciprocal
state
• If the operator does not have working
experience in a comparable grade plant,
that person will be granted a lower grade
of certification, as warranted
Reciprocity
• With an Alabama certification, attaining
reciprocity in another state is more likely
to occur in the future [without the reg
change, reciprocity would be in jeopardy]
• Reciprocity is likely to become a more
significant issue for operators looking to
attain reciprocity with Alabama
Industrial WW Treatment
Plant Operators
• Not required, but ADEM will allow people
with suitable equivalent industrial
experience to pursue and attain certification
UIC or Decentralized
WWTP Operation
• Certification will be required in
accordance with ADEM-issued UIC
permits
– Decentralized WWTP operators will be
required to meet Division 10 regulations.
In most cases, these will be Grade I
WWTPs but the plants must be ranked just
like an NPDES-permitted system
– Collection system requirements apply
Conclusion
• We need to update our regulation to meet
the broadened responsibilities of today’s
certified operators
• ADEM wants to ensure that we have a
robust Operator certification program in
the years ahead
• We will get through this together
• We want your feedback
Conclusion
Questions..?
Jim Grassiano
Chief, Compliance Assistance & Operator Certification Programs
334-279-3071
Mary Alice Corcoran
Compliance Assistance & Operator Certification Programs
334-271-7872
mailto:[email protected]:[email protected]Top Related